The passport record a defence original equipment manufacturer (OEM) keeps is the battery passport record for each battery that falls inside Regulation (EU) 2023/1542, built to the Annex XIII information set, linked to the battery through a data carrier, and held with the evidence behind each entry and the scope reading that placed the battery inside the Regulation. The record applies where the OEM places a light means of transport battery, an industrial battery with a capacity greater than 2 kWh, or an electric vehicle battery on the Union market or puts such a battery into service from 18 February 2027, the date fixed in Article 77 of the Regulation. Defence identity does not create a separate passport record type, and a defence OEM keeps the same kind of record as any other manufacturer for a battery that is inside the Regulation.
In this guide, a defence OEM means a manufacturer of equipment made for defence use, and the passport record means the full record set for one battery: the passport data itself, the carrier that resolves to that data, the version history of the data, and the evidence file that supports each entry. The scope of this guide is the record itself: identity, evidence, scope reading on file, and limits. The scope boundary question, namely whether a particular defence battery falls inside or outside the Regulation at all, is treated only briefly here, and the companion guide on defence applications carries the full boundary method. This guide does not advise a specific OEM on its own position, and it does not decide whether any particular battery is inside the Regulation.
What identity does the record carry?
The record starts with identity, because a passport that cannot be tied to one battery cannot be checked. The identity entries name the battery model, the battery category under the Regulation definitions, the manufacturer identity, and the unique identifier that the data carrier resolves to. The category entry matters for a defence OEM, because specialist equipment often carries batteries that look alike across categories, and the category decides whether a passport duty applies at all. A battery in a specialist vehicle, a specialist power system, or a specialist installation is commonly industrial where it is designed for industrial or professional use, but the category entry must follow the Regulation definitions in Article 3, not the identity of the end user or the name of the equipment programme.
The placing entry sits beside the identity entries, recording the date the battery was placed on the market or put into service, the act that constituted that placing, and the operator who carried it out. The placing date is the anchor for the 18 February 2027 threshold in Article 77, so a record that lists only a manufacture date or only a later sale date cannot prove that the threshold was met.
What evidence sits behind each entry?
Every passport entry needs evidence behind it, and the evidence file is part of the record, not an optional extra. The evidence file holds the source document or test record for each entry, the date of that source, and the name of the role that checked it. A composition entry points to a materials declaration from the supply chain; a capacity entry points to a measurement made by a stated method on a stated date; a carbon entry points to a declaration prepared by a stated method for a stated reference period. An entry without a pointer to evidence is a claim, and a claim cannot be checked by a market surveillance authority, a customer, or a later reader inside the OEM itself. The method behind each figure matters as much as the figure itself, so the evidence pointer for a materials or carbon entry should name the method and the date of the underlying declaration, alongside the figure. A carbon entry that depends on a delegated act detail not yet settled should be shown as expected rather than settled, with the act named and the position dated as checked on 30 October 2026.
The evidence file also needs a gap register, listing each entry that is incomplete, the reason it is incomplete, and the action that would close it. A gap stated openly, with a closing action and a date, keeps the record honest, while a gap hidden by an approximate entry corrupts the record, because a later reader cannot tell which entries were checked and which were estimated.
How is the scope reading kept on the record?
A defence OEM record carries a scope note, because the scope question is the first question for a defence battery and the answer must be visible on the file. The scope note records the Regulation wording read, the facts of the battery and the equipment, the comparison between the wording and the facts, and the conclusion drawn from that comparison. The note should quote or closely paraphrase the Article 1 wording relied on, and it should name the facts that matter: the equipment, its purpose, and the role of the battery inside that equipment.
The scope note also records uncertainty where uncertainty exists. The companion guide on defence applications explains why a general defence exemption is uncertain, and this guide does not repeat that argument. Where the scope reading is uncertain, the record should say so, state what fact or legal reading would resolve it, and state the basis on which the battery is being handled in the meantime.
What does a worked record look like?
The table below shows a worked record for a single illustrative battery. Every value in the table is a placeholder labelled illustrative, and no value is a measurement from a real battery.
| Record field | Illustrative entry | Evidence pointer |
|---|---|---|
| Battery model | Illustrative model reference DEF-IND-001 | Model register entry dated 30 October 2026 |
| Category | Illustrative industrial category entry | Article 3 definition check dated 30 October 2026 |
| Capacity | Illustrative capacity value of 5 kWh by a stated test method on a stated test date | Test record reference, method and date on file |
| Placing date | Illustrative placing date of 20 February 2027 | Placing act record for that battery identifier |
| Scope note | Illustrative scope note quoting the Article 1 wording relied on | Scope note dated 30 October 2026 |
| Carbon entry | Illustrative carbon entry labelled expected pending the applicable delegated act | Method note dated 30 October 2026 |
The discipline shown here scales: one field, one entry, one pointer, one date. Each version of the record should also be kept: a correction creates a new version with the date, the field changed, the old entry, the new entry, and the reason, while the old version stays on file rather than being overwritten.
What stays out of the record?
Access to the record is tiered under Annex XIII, so not every reader sees every entry, and each entry should be tagged with its tier when it is created. Public entries are open to any reader who resolves the carrier, further entries are open to readers with a legitimate interest, and further entries still are open to market surveillance authorities, notified bodies, and the Commission. For a defence OEM, tier tagging needs care around sensitive equipment information. The passport entries concern the battery, not the equipment programme, and the record should keep that boundary visible: battery composition, battery performance, and battery safety information belong in the record under their tiers, while equipment programme detail that is not a battery passport entry does not belong in the record at all.
What limits apply to this guide?
This guide describes the shape of a passport record for a defence OEM and does not decide the scope status of any battery, the category of any particular battery, or the position of any specific OEM. This guide gives general educational information only and is not individual legal advice. A reader with a specific battery or a specific placing decision should check the current Regulation text and any applicable delegated or implementing act before acting, and should seek appropriate advice where the scope reading or a record entry is uncertain.
Sources & further reading
Source links point to primary materials and further reading, including commercial implementation resources where cited. This introductory guide does not replace the legislation.